The gender pay gap, that is the average pay difference between men and women, remains one of the main inequalities in the workplace and, despite growing attention, it still hasn’t been closed. According to EIGE, the European Institute for Gender Equality, women in the EU earn on average only 77% of what men earn annually: this means that, to make the same income men earn in a year, women on average have to work 15 months and 18 days. This period, also known as the “ghost quarter,” represents time taken away from family, studying, training, or rest.
Even in Italy, according to the 2026 INPS gender report, last year men earned more than women across all economic sectors, with half of the sectors analyzed (9 out of 18) where women earn more than 20% less.
The Salary Satisfaction Report 2026 by JobPricing, carried out in collaboration with Adecco, also confirms how closely pay is linked to personal motivation: overall satisfaction with one's salary package stands at a 4.2 out of 10, with the lowest scores related to merit recognition (3.6) and trust in the relationship between the organization and the employee (3.9).
EU Directive 970/2023: what changes in recruitment and hiring
Europe has tackled this topic with European Directive 970 of 2023 on Pay Transparency, which aims to bring more clarity and fairness to pay systems, but still has some elements that are tricky to apply: the regulation might not fully account for certain parts of compensation, like extra pay and bonuses, which can significantly affect pay gaps.
This makes assessing pay equality more complicated and could lead to an application mostly based on the collective labor agreements for pay audits required by the regulation. Companies will need to adjust their recruiting processes by introducing more transparency.
- Indication of the RAL or salary range in job ads: salary information must be available already when the position is published.
- Ban on asking about a candidate’s previous salary: companies will no longer be able to use past earnings as a factor in the hiring process.
- Workers’ right to get info on average pay levels: starting June 7, employees can request information about average salaries for comparable positions, with data broken down by gender.
In Italy, the Directive was implemented with Legislative Decree No. 96, which came into effect on June 7, 2026. The decree introduces some relevant specifics compared to the European framework, particularly regarding the role of collective bargaining and the obligations applicable to companies:
- Centrality of National Collective Labour Agreements (CCNL): the definition of 'same work' and 'work of equal value' is linked to the job classification levels and the criteria set out by the CCNL applied by the company or, in its absence, by the collective agreement signed by the most representative trade unions.
- Legislative Decree 96/2026 actually distinguishes between 'remuneration,' understood as the sum of fixed, variable and complementary components paid by the employer, and 'pay level,' referring to annual and hourly gross pay and continuous and fixed elements, excluding some non-structural individual treatments.
- Transparency on pay criteria: the decree strengthens the requirement to make the criteria behind pay and career progression understandable.
- Aggregate information: workers can ask for average pay levels, broken down by gender, for those doing the same job or work of equal value, without accessing individual salaries of their colleagues.
- Ban on pay secrecy: clauses that prevent workers from disclosing their own pay are null and void.
- Reporting obligations based on company size: the frequency and start of reporting on the gender pay gap vary depending on the number of employees, with annual requirements for companies with at least 250 workers and every three years for companies with 150 to 249 employees.
The main changes introduced by the regulations for companies
In light of what has been said, for businesses with fewer than 100 employees, some obligations can be carried out on a voluntary basis, while for larger companies, the new Decree introduces specific requirements that must ensure greater transparency regarding the components that determine pay, including variable ones, for example:
- Selection processes: more clarity during the selection phase to avoid biases in the salary offer;
- Criteria and communication: transparency regarding the criteria that determine salaries and career progression;
- Right to individual transparency: employees' right to request information about their own pay;
- Reporting and Gender Pay Gap: reporting starting in 2027 and relationships with trade unions.
To deal with the new regulations, companies will need to:
1) analyze salary data, identifying any risky situations that need to be addressed first and create analysis and monitoring reports on the gender pay gap that can explain differences above 5%;
2) distinguish between the “raw gap” – based on comparing average salaries – and the “residual gap” – calculated based on legitimate individual differences – taking into account factors like experience, seniority, and skills;
3) equip themselves with effective management tools – starting from the national collective labor agreement or using an organizational analysis tool, like Job Evaluation, which allows determining the “value” of roles within an organization based on objective professional criteria.
Introducing pay transparency requires companies to combine objective criteria for evaluating work with a review of HR processes. Data on the gender pay gap serve as a starting point to identify risk areas and understand the causes of pay differences. It will also be necessary to make the criteria for setting and progressing salaries more transparent and to review selection, evaluation, and development processes. More than just a regulatory requirement, pay transparency therefore requires an organizational change and change management journey that involves processes, tools, managers, and company culture.